ABS CCC 8 Brief
ABS CCC 8 Brief
ABS CCC 8 Brief
OTHER DEVELOPMENTS
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• Special Provisions for the Transport of Vehicles
• Amendments to the International Grain Code
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• Recommendations for Entering Enclosed Spaces Aboard Ships
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As with the IGF Code, risk assessments will be the basis for designing ships using LPG as fuel safely. The Interim
Guidelines contain requirements for several risk assessments beyond those required by the IGF Code. Ventilation
safety requirements unique to LPG fuel were introduced in recognition that LPG gas may accumulate at the bottom
of rooms or even open deck due to its density. These Interim Guidelines will apply to ships using LPG as fuel to
which Part G (Ships using low-flashpoint fuels) of SOLAS Chapter II-1 is applicable and requires compliance with
the IGF Code.
The Sub-Committee also considered a proposal for safety requirements for the use of LPG cargo as fuel. While it
was recognized that there is an increasing demand for the use of LPG cargo as fuel in LPG carriers, the Interim
Guidelines discussed above have yet to be approved by the MSC, and the development of safety requirements for
using LPG cargo as fuel may be more appropriately developed under the IGC Code rather than the IGF Code. For
these reasons, this proposal will be addressed by a future session through the IGC Code.
Next Steps: The above noted draft MSC circular will be presented to MSC 107 (June 2023) for further
consideration and approval.
Discussions focused on the main concepts and principles of using hydrogen as fuel. The main concepts under
consideration included:
1) Preliminary discussion on distinguishing fuel cell space vs. fuel cell compartment.
2) Identified the need to distinguish between systems in which hydrogen cylinders are exchanged vs.
systems employing hydrogen bunkering.
3) Identified the need to distinguish requirements for bunkering of liquefied vs. compressed hydrogen.
4) Consideration of “acoustic detection” as a viable means of detecting hydrogen gas leaks (high pressure
leaks typically emit an ultrasonic noise whose frequency can be distinguished from other lower frequency
sounds)
A Correspondence Group has been established and will develop specific provisions covering these concepts, for
submission to CCC 9 (Sept. 2023).
The Sub-Committee also considered proposals to revise the Interim Recommendations for Carriage of Liquefied
Hydrogen in Bulk (resolution MSC.420(97)). However, due to time constraints and the current workload, it was
Next Steps: Work on the draft interim guidelines for ships using hydrogen as fuel will continue intersessionally,
with the intention to finalize the interim guidelines at CCC 9 (Sept. 2023).
The Sub-Committee briefly discussed the ongoing development of interim guidelines detailing the use of oil fuels
with a flashpoint between 52°C and 60°C, covering oil-based fossil fuels, synthetic fuels, biofuels and any mixture
thereof. It was noted that this work item was initiated at a time when concerns existed that the global supply of low-
sulphur fuels would be insufficient to meet demand in the 2020 transition to 0.50% sulphur fuels, and so ships
would need to look toward fuels with flashpoints lower than 60oC. While this concern has not materialized, it was
agreed that this work should continue in order to provide a path forward for new alternative fuels which may fall
below 60oC flashpoint.
Next Steps: Work on this subject will continue intersessionally and be discussed further at CCC 9 (Sept. 2023).
The Sub-Committee also noted the view that the use of ammonia as fuel conflicts with existing mandatory
instruments. MARPOL Annex VI/Regulation 18 and IGC Code Chapter 16 both prohibit the use of toxic or harmful
fuels. Despite this, the Sub-Committee determined that this work should be initiated as agreed by MSC. Once
these guidelines are finalized, MSC can consider the legal implications of this fuel type.
Next Steps: Work on this subject will continue intersessionally with further discussion during CCC 9 (Sept.
2023).
Work Plan for the Development of Safety Provisions for Alternative Fuels
The Sub-Committee agreed to the following timeline for the development of several standards for alternative fuels
through the IGF Code. The scope of remaining work extends to 2025, and includes development of standards for
LPG, Low-Flashpoint Oil Fuel, Hydrogen, Ammonia and Methyl/Ethyl Alcohol fuel standards, and may extend to
development of a mandatory instrument for use of fuel cells.
Next Steps: Developments under this Work Plan will continue through at least the next three sessions of the
Sub-Committee.
Next Steps: These draft amendments will be presented to MSC 107 (June 2023) for consideration and
approval. Approved amendments will be presented for adoption at MSC 108 (Spring 2024).
Next Steps: The Sub-Committee agreed to hold proposed amendments to the IGC Code in abeyance until
CCC 9 (Sept. 2023) for incorporation into a new consolidated edition of the IGC Code.
Next Steps: Results of a completed test of high manganese austenitic steel for ammonia service are expected
to be submitted to CCC 9 (Sept. 2023), for further discussion and assessment.
1) IGF Code, Paragraph 9.2.2 – Specific Requirements for Ships Using Natural Gas as Fuel / Fuel Supply to
Consumers
This UI clarifies fuel transfer system piping requirements, specifying that use of flange connections should
be kept to a minimum. This interpretation was agreed, and will be presented for approval by MSC 107
(June 2023) and subsequent publication as an MSC circular.
2) IGF Code, Section 5.8 – Design of Fuel Preparation Rooms Not Located on Open Deck
a) IGF Code, Paragraph 5.11.3 and 12.5.3.2 – Access Arrangements and Associated Hazardous Areas
This UI proposes clarifications to certain tank connection space requirements for the design of fuel
preparation rooms not located on the open deck. This interpretation was agreed, and will be presented for
approval by MSC 107 (June 2023) and subsequent publication as an MSC circular.
Next Steps: The above noted Unified Interpretations will be progressed as detailed above.
Next Steps: E&T 38 has been tasked by the Sub-Committee to develop the 42-24 Amendments to the IMDG
Code, and will submit a report on this to CCC 9 (Sept. 2023).
Implementation of a new Substance Identification Number (SIDN) for solid bulk cargoes was proposed. This SIDN
would supplement the current system of identifying cargoes under the IMSBC Code by Bulk Cargo Shipping Name
(BCSN). However, concerns were raised regarding the logistics of implementing a new system of identifying and
documenting bulk cargoes, such as the updating of shipping databases worldwide to consistently identify such
cargoes. There were no objections to the utility of such an identification system, and it was agreed that the rules of
the numbering system and the timeline for a global transition to its use would need to be developed.
Discussions regarding the implementation of a SIDN system for solid bulk cargoes will continue at E&T 38 and a
report made to CCC 9 (Sept. 2023), and the proposal will not be introduced into Amendment 07-23 of the Code.
Revisions to Regulation 31 of this chapter require the master of every ship involved in the loss of freight containers
to communicate details of the incident to other ships in the vicinity, to the nearest coastal State and also to the flag
State. In the event that the ship is abandoned or otherwise unable to complete this reporting, the ISM management
company of the vessel must assume responsibility for this reporting to the fullest extent possible. For vessels not
involved in a loss incident but observing a freight container drifting at sea, the master of the ship is obligated to
report such observations to other ships in the vicinity and to the nearest coastal State. Associated revisions to
Regulation 32 of the same chapter provide a list of information to be collected when reporting the loss of freight
containers from a ship or the observation of freight containers drifting at sea.
In conjunction with these SOLAS amendments, the Sub-Committee also finalized development of a draft
amendment to Article V (Reporting Procedures) of Protocol I (Reports on Incidents Involving Harmful Substances)
of the MARPOL Convention. This amendment inserts a cross-reference to the revised Regulations 31 and 32 of
SOLAS Chapter V and establishes the reporting of lost freight containers as an obligation under the MARPOL
Convention as well.
Next Steps: The above noted draft amendments to SOLAS Chapter V will be presented to MSC 107 (June
2023) for further consideration and approval, and subsequent adoption at MSC 108 (Spring 2024). The currently
anticipated date of entry into force for these amendments is 1 January 2026.
The above noted draft amendment to MARPOL will be forwarded to the MEPC for adoption at a future session,
pending concurrent adoption of the SOLAS Chapter V amendments by the MSC.
Development of New GISIS Module for Reporting Containers Lost or Observed Adrift at Sea
To better facilitate the reporting and assessment of freight container losses, the IMO Secretariat has been asked to
develop a new module in the IMO GISIS platform which will provide an online portal for reporting these incidents.
Reporting in this new GISIS module will allow reports to be updated, as it has been recognized that some container
loss incidents require time for investigation, and further details may be established before a final report is made.
Next Steps: The IMO Secretariat will prepare to develop the new GISIS module for reporting of freight
containers lost at sea. This is subject to the adoption of the above-mentioned SOLAS and MARPOL
amendments by the MSC and MEPC, respectively.
Next Steps: The Sub-Committee acknowledged that the expected outcomes of ongoing research would give a
clearer basis for identification of root causes for container losses and provide more effective recommendations
to increase container safety. Relevant information on this is expected to be received by MSC 106 (Nov. 2022),
and further steps determined afterward.
OTHER DEVELOPMENTS
Special Provisions for the Transport of Vehicles
The Sub-Committee received a proposal to replace special provisions (SP) 961 and 962 of the IMDG Code with a
new special provision 9XX in response to recent fire incidents occurring on vehicle carriers. SP961 provides
exceptions from dangerous goods regulations for vehicles when certain conditions are met. SP962 outlines the
requirements for vehicles not meeting the conditions of SP961 and emphasizes that the marking, labelling,
placarding and marine pollutant provisions of the Code are not applicable to vehicles transported under SP962.
Recent fire incidents on board roll-on/roll-off vessels raised concerns over the wide applicability of the SPs to all
vehicles and to the exceptions provided in the special provisions.
The proposed new SP9XX would apply to vehicles powered by fuels classified as dangerous goods via internal
combustion systems, batteries or fuel cells. Among the conditions of this proposed new special provision are:
1) Required inspection of vehicles before being loaded on a ship, to check for signs of leakage from the
battery, engine, fuel cell, compressed gas cylinder or accumulator, or fuel tank where applicable, and to
ensure there are no identifiable faults in the electrical system that could result in short circuit or other
unintended electrical source of ignition. A vehicle showing any signs of leakage or electrical fault shall not
be transported.
2) Limitations on the quantity of fuel permitted in the vehicles’ tanks.
3) Conditions for the lithium batteries in transport of vehicles powered solely by lithium batteries and hybrid
vehicles, including limits on the state of charge in the batteries.
4) Restrictions on the transport of damaged vehicles.
Discussion during this session of the Sub-Committee was limited. An intersessional Correspondence Group was
established to continue developing these new transport provisions.
Next Steps: Work on this subject will be progressed intersessionally and discussed further at CCC 9 (Sept.
2023).
This definition refers to a compartment which is not filled to the maximum extent possible in way of the hatch
opening but is filled to a level equal with or above the bottom edge of the hatch end beams and has not been
trimmed outside the periphery of the hatch opening by the provisions of regulation A /10.4 of the Grain Code. In
such compartments, the bulk grain shall be filled to a level equal with or above the bottom edge of the hatch end
beams but may be at its natural angle of repose outside the periphery of the hatch opening. After loading, only the
free grain surface in way of the hatch opening shall be level. A compartment may qualify for this classification if it
is "specially suitable" as defined in regulation A/2.7 of the Grain Code, in which case dispensation may be granted
from trimming the ends of that compartment.
Additional amendments in Part B of the Grain Code addressing calculation assumptions have also been made to
provide guidance on the assumed slope of the cargo when partly filled in way of the hatch opening with ends
untrimmed, for the purpose of determining the assumed volumetric heeling moment.
Next Steps: The above noted draft amendments will be presented to MSC 107 (June 2023) for further
consideration and approval, and subsequent adoption at MSC 108 (April 2024). The currently anticipated date
of entry into force for these amendments is 1 January 2026. The amendments will be applicable to new and
existing ships, and the stability booklet should include relevant information before the first time a ship is loaded
in accordance with the newly specified loading conditions on or after the date of entry into force.
Next Steps: The Sub-Committee will await the outcome of MSC 106 (Nov. 2022) to see if the MSC approves a
new output for a more comprehensive revision of resolution A.1050(27), and may consider this discussion on
“enclosed spaces” at a future session.
It was recognized that lashing software is widely used, and Member States supported the proposed use of lashing
software as a supplement to the Container Stowage and Securing Plan. However, it was agreed that this proposal
exceeded the scope of a UI. Further proposals are needed to harmonize the use of the method, including
Next Steps: Sub-Committee did not support this proposed Unified Interpretation, but invited interested parties
to submit proposals for new output to address approval and recognition of lashing software as part of the
Container Stowage and Securing Plan.